Cyprus Ukraine DTA Changes :There have been amendments to the existing Double Tax Agreement (DTA) between Cyprus and Ukraine. These changes have only been agreed recently:
Ruling Tax Matters Administrative Fee :Ukraine’s Government
The Government of Ukraine has announced those changes to the existing double tax agreement after negotiations between the two countries.
Summary of Amendments:
- Immovable Property Income
Cyprus Ukraine DTA Changes: The existing DTA provides that income from immovable property located in Ukraine was exempted from taxation in Ukraine. The new DTA changes this exemption or otherwise escape from taxation in Ukraine. Any income now received by residents of Cyprus from the sale of shares on any other sale of other corporate rights will not escape and will be subject to tax in Ukraine. The above rule only applies if the value of the relevant income from the proceeds exceeds 5o percent of that income.The income can be either directly or indirectly in connection with income from immovable property that is located in Ukraine.
- Tax rate on Dividends
Cyprus Ukraine DTA Changes: There has been a rise on the minimum taxation rate on dividends which comes to 5 percent from the previous 2 percent. The new minimum lower rate would apply in the case where the recipient owns 20 percent or higher of the company shares which provides that dividend to the recipient. The recipient must also have invested the minimum of EUR100, 000 in order to acquire the said shares. In any other case, a rate of ten percent would apply and not the lower rate as described above.
The above changes on dividends will become effective no earlier than January 1, 2019. Other changes have been proposed and are expected to be implemented in line with the OECD international tax standards.
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